|OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
May 2, 2002
Mr. Robert Garrett
Roof Mates, Inc.
1450 Grimm Road, Suite 4
Severn, MD 21144
STD 3-0.1A, Subpart M, 1926.250, 1926.500
Dear Mr. Garrett:
We are in receipt of your letter, dated November 30, 2001, in
which you ask us to review several Roof Mates roofing products
and give you any feedback that we may have about your products.
As a result of government mail delivery delays due to the anthrax
decontamination process, we did not receive your letter until
January 17, 2002. We apologize for the long delay in
OSHA is generally precluded from approving or endorsing
products. Also, the variable working conditions at job sites and
possible alterations or misapplication of an otherwise safe
product could create a hazardous condition beyond the control of
the manufacturer. However, where appropriate, we try to give some
guidance to help employers assess whether products are
appropriate to use in light of OSHA requirements.
Products like your Roofer's Rack, Tool Box, Bracket,
and Stocker would appear to help construction employers
comply with several of the requirements in §1926.250,
Material Handling, Storage, Use, and Disposal. For
instance, paragraph (a), General, of this section requires
that all materials stored in tiers shall be stacked, racked,
blocked, interlocked, or otherwise secured to prevent sliding
falling, or collapse. Likewise, paragraph (c),
Housekeeping, requires that storage areas shall be kept free
from accumulation of materials that constitute hazards from
tripping, fire, explosion, or pest harborage.
These products also
appear to help comply with section D of our directive for Interim Fall Protection Compliance Guidelines for Residential Construction, [STD 03-00-001 (formerly STD 3-0.1A)], which requires that supplies and materials shall not be stored within 6 feet of the rake edge, or 3 feet where tile and roof systems are being installed.
[This document was edited on 12/5/12 to strike information that no longer reflects current OSHA policy]
Thank you for submitting information to us about your products;
such information helps us stay current with respect to the range
of safety products available on the market, especially in the
commercial and residential homebuilding industry.
If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.
Russell B. Swanson, Director
Directorate of Construction